EXHIBIT 16.1

                           SPEAR, SAFER, HARMON & CO.
                            PROFESSIONAL ASSOCIATION
                          CERTIFIED PUBLIC ACCOUNTANTS
                        8350 N.W. 52ND TERRACE, SUITE 301
                              MIAMI, FLORIDA 33166
                                 1-800-776-1099
                               TEL: (305) 591-8850
                               FAX: (305) 593-9883
April 28, 2004

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:      Andean Development Corp.
         File Ref. No. 33-90696

Dear Sirs/Mesdames:

We were previously the principal accountants for Andean Development Corp. and we
reported  on  the consolidated financial statements of Andean Development  Corp.
and Subsidiaries as of the period since December 31, 1995.  As of this date,  we
were  not  engaged as the principal accountants for Andean Development Corp.  We
have  read Andean Development Corp.'s statements under Item 4 of its Form  8-K/A
dated April 28, 2004 and we agree with such statements.

  For  the  most  recent fiscal year of 2002 and any subsequent interim  period,
there  has  been  no disagreement between Andean Development  Corp.  and  Spear,
Safer,  Harmon  &  Co  on  any  matter of accounting  principles  or  practices,
financial   statement  disclosure,  or  auditing  scope  or   procedure,   which
disagreement, if not resolved to the satisfaction of Spear, Safer, Harmon  &  Co
would  have  caused  it  to  make  a reference to  the  subject  matter  of  the
disagreement in connection with its reports.

Very truly yours,

SPEAR, SAFER, HARMON & CO.